Smith v. Indiana

Background

A county auditor in Indiana sought review after state courts considered the constitutionality of an Indiana exemption law. The case was argued in state circuit and supreme courts and the state supreme court upheld the law. The auditor pursued the matter in his official role, apparently to test the law for the benefit of taxpayers rather than for any personal gain.

Reasoning

The Court examined whether the auditor had a personal interest sufficient to bring this appeal to the United States Supreme Court. It said that although state officers sometimes refuse to enforce statutes they believe unconstitutional, this Court’s power to hear a case requires a party with a personal stake. Relying on prior decisions, the Court concluded the auditor’s duties and any liability for costs did not create the necessary individual interest, so he could not sue on behalf of third parties.

Real world impact

The ruling prevents public officials from using this Court to decide constitutional questions solely for others when they lack individual rights at stake. Because the appeal was dismissed for lack of interest, the Court did not rule on the constitutionality of the Indiana exemption law and that question remains unsettled in federal court for now.

Dissents or concurrances

Two Justices (Harlan and White) disagreed and would have allowed the auditor to press the appeal and wanted the Court to decide the merits of the constitutional question.